In this month’s PCI SSC QSA Newsletter, the FAQ of the Month is about so called ‘PCI DSS Compliance Certificates’. I started to hear about these a couple of years ago, but it got really big last year when I started running into processors and acquiring banks demanding them. I had a particularly troubling conversation with a processor who demanded that we produce one for one of our clients. When offered the PCI DSS Attestation Of Compliance (AOC), this processor acted as though we were trying to put something over on them. When I asked him where I was supposed to get such a certificate when it does not exist on the PCI SSC Web site, he accused me of not being a QSA because all QSAs know what the certificate looks like and where to get it.

As a result, a lot of QSAs must have submitted a question regarding these certificates like I did. Here is the PCI SSC’s response.

“In addition to the official PCI SSC reporting forms and templates, some QSA or ASV companies provide certificates, letters or other documentation as confirmation that an organization is PCI DSS compliant. The PCI SSC does not prevent QSAs or ASVs from producing this type of documentation, as it is considered an additional service which the assessor company may elect to provide and is therefore outside of the purview of the Council. However, in accordance with the ethical requirements for QSA and ASV companies, any such certificates, letters and other documentation must be accurate and not be in any way misleading. Additionally, these certificates, letters and other documentation should be clearly identified as supplemental materials provided by the QSA or ASV; they should not be presented as documents endorsed by the PCI SSC, nor should they be considered replacements for the official PCI SSC templates and forms which have been approved by the payment brands.

The PCI SSC website contains reporting templates and forms which have been approved by all payment brands, including ROC templates, Attestations of Compliance, Self-Assessment Questionnaires, and Attestations of Scan Compliance for ASV scans. Compliance validation and reporting requirements are determined by the individual payment card brands and, irrespective of whether an organization is performing a self-assessment or has an onsite review completed by a QSA company, acceptance of a validation method outside of those listed on the Council website is ultimately up to the entity accepting the validation (that is, the acquiring bank or payment card brand). In many cases, certificates, letters or other documentation issued by QSA or ASV companies outside of the official PCI SSC templates may not be accepted by acquiring banks or payment card brands. ASVs and QSAs should encourage their clients to check with their acquirer or the payment brands directly to determine their compliance reporting requirements, including whether the submission of such certificates is acceptable.”

So all of you processors and acquiring banks that seem to think the only acceptable proof of PCI compliance is some mystical PCI DSS Compliance Certificate, stop demanding them. They do not exist and never have existed. The document you need for proof of PCI compliance is the Attestation Of Compliance (AOC), period. All self-assessment questionnaires (SAQ) contain the AOC and there is a separate AOC form for those submitting a Report On Compliance (ROC).

And all of you QSAs and ASVs out there differentiating yourselves because you produce these nice, but essentially worthless, certificates, stop misinforming merchants, processors and acquiring banks by implying that QSAs and ASVs not producing such a certificate are somehow doing something wrong or worse, dishonest.

Now that the PCI SSC has clarified this situation, hopefully, this marketing ploy will stop.

Merchants and service providers are supposed to assess their PCI compliance annually. Not that organizations cannot work with service providers that are not PCI compliant. But if an organization chooses to work with a non-PCI compliant service provider, then the organization is responsible for including the service provider in their own assessment for the services provided to their organization.

No. There are still QSACs that are issuing these worthless certificates and their service provider customers are still handing them out and then telling QSAs that the certificate is the same as the AOC.

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